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Imagine a world without fuel for our cars, drugs to treat diseases, or even technology like the device you are currently using. Every day we rely on the innovations of modern chemistry to make our lives safer, healthier and more sustainable.

But what if guidelines were put in place that could jeopardize these chemicals and innovations? When activist groups like Safer Chemicals Healthy Families herald a one-size-fits-all approach to banning, restricting, or regulating entire chemistry classes, it is fueling a misguided move that could have a significant impact on our society.

The truth is that this is not an effective science-based policy. As an industry, the American Chemistry Council (ACC) is committed to addressing potential chemical concerns and supports strict regulations to protect human health and the environment. However, the increasing practice of banning, restricting or regulating entire classes of chemicals without recognizing their individual properties and behaviors is neither scientifically correct nor appropriate.

Let’s think of this as something we’re all very familiar with: berries. There are some that we eat – like blueberries, raspberries, and strawberries. And then there are those that are inedible – like holly berries and ivy berries. If these berries are consumed, they can make you sick.

They can all be called “berries” – but they are all very different.

The ban on ALL berries – because you pose a potential risk – makes no sense. The same applies to chemicals such as phthalates, bisphenols, fluorinated chemicals and flame retardants. While the names of the chemicals may be similar, the differences in their use, structure, safety, and environmental profiles make them unique.

Those who work in the chemical industry today are focused on tomorrow’s needs. To build a more sustainable future, chemistry is vital. By banning entire families of chemicals, we are eliminating many of the achievements, innovations, and useful products that each chemical can make possible in those families now and in the future. The result can be a safer, more sustainable, and more innovative world for all of us.

Interested in a little more food for thought? ACC and its members work with downstream users, retailers, manufacturers and government regulators to support the safe use of chemicals in consumer products. Visit MindtheScience.org for more science-based information about how some of the chemicals you may read about can be used in consumer products. the important benefits they can offer; and safety tests and assessments that these chemicals have undergone.

Recent research reveals deficiencies in grouping

But don’t take our word for it. A scientific consensus is emerging that it is not accurate, or even possible, to group all PFAS chemicals together for regulatory purposes. Indeed, state and federal agencies that have explored the possibilities of a class-based approach have recognized the significant challenges.

For example:

  • ECOS1 – The State Environment Council, which represents the leaders of state and territorial environmental agencies, some of which have implemented regulatory programs in their home states, said, “Many regulators and subject matter experts do not recommend grouping PFAS as a whole class.”
  • The Vermont Department of Environmental Conservation2, who was specifically mandated by the legislature to develop a class regulation or explain why such a regulation was not possible, said: “The review team has thought, researched and discussed the potential for regulating PFAS as a class for over a year. After reviewing the current literature and the available toxicological data for PFAS, the review team determined that it is currently not possible to regulate PFAS as a class. “
  • And federal scientists who took part in a workshop called last autumn by the National Academies for Science, Technology and Medicine (NASEM) to review the federal PFAS research program recognized the great diversity of the properties of this group of substances and came to this Conclusion that3 “PFAS substances therefore pose a unique challenge for the classification into classes for risk assessment.”
  • These state and federal agency findings are also corroborated in a recent peer-reviewed scientific paper4th Evaluation of possible grouping frameworks for evaluating PFAS.

  1. ECOS. Processes and considerations for setting state PFAS standards (February 2020).
  2. https://dec.vermont.gov/sites/dec/files/PFAS/20180814-PFAS-as-a-Class.pdf.
  3. NASEM. Workshop on PFAS research by the German government on human health, 26.-27. October. Committee on Environmental Studies and Toxicology (2020). https://www.nap.edu/read/26054/chapter/1.
  4. Goodrum PE et al. Applying a Framework for Grouping and Assessing Toxicity of PFAS Mixtures: A Closer Examination of Approaches to Dose Additivity. Toxicol Sci: 1-19 (2020). https://doi.org/10.1093/toxsci/kfaa123.

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